CosmeticOBS - L'Observatoire des cosmétiques
April 10, 2010Learning to read labels

Mandatory mentions … on purpose! Add to my portfolio
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Some regulatory mentions are mandatory and manufacturers shall have them printed on the packaging of their cosmetics. These are pieces of information that the lawyers think must be made available for the average consumer. Very often, our eyes are unmindful of these small print …but, if there are available, it is likely they are useful! Here are some clues on how to use them …

Reading time : ~ 12 minutes

The basis for this is the Article 19 of the future Regulation on Cosmetic Products 1223/2009; nevertheless, the same requirements are in the currently implemented Directive pertaining with cosmetics.

In its first paragraph, there is a clear requirement: "Without prejudice to other provisions in this Article, cosmetic products shall be made available on the market only where the container and packaging of cosmetic products bear the following information in indelible, easily legible and visible lettering":

The name or registered name and the address of the responsible person

This is the legal or natural person designated within the Community as "responsible person" who, for each cosmetic product placed on the market, shall ensure compliance with the relevant obligations set out in this Regulation.
Such information may be abbreviated in so far as the abbreviation makes it possible to identify that person and his address.

For which purpose?
• For the sanitary authorities, this is a means to identify quickly who will be the contact for any breach of regulation, a concern with the product, a warning from Cosmetovigilance.
• The consumer is sure he could get additional pieces of information further to those printed on the packaging.

The Article nbr 21 of this Regulation is self-explanatory: "Without prejudice to the protection, in particular, of commercial secrecy and of intellectual property rights, the responsible person shall ensure that the qualitative and quantitative composition of the cosmetic product and, in the case of perfume and aromatic compositions, the name and code number of the composition and the identity of the supplier, as well as existing data on undesirable effects and serious undesirable effects resulting from use of the cosmetic product are made easily accessible to the public by any appropriate means".
In plain English, this means that if one worries about the presence of a specific ingredient (especially if one is allergenic ), one is entitled to ask information that could be useful to prevent any reaction. One may send a message to the name and the address of the responsible person, who shall give you an answer.

The nominal content at the time of packaging, given by weight or by volume

There are two exceptions to this rule, already given here. It does not apply to packaging containing less than five grams or five millilitres, free samples and single-application packs; for pre-packages normally sold as a number of items, for which details of weight or volume are not significant, the content need not be given provided the number of items appears on the packaging. This information need not be given if the number of items is easy to see from the outside or if the product is normally only sold individually.

For which purpose?
Just to know what one pays for. It is useless to remind our readers that the size of a packaging may be misleading (very large while containing a 15 mL/ ½ fl. oz bottle), that a bottle may “shrink” from one year to another while the price is steady, etc …
The exact volume/mass allows for the comparing the exact price of a similar quantity (say, 100mL/a bit less than 4 fl.oz) of another product.

Date of minimum durability

It is the date until which the cosmetic product, stored under appropriate conditions, will continue to fulfil its initial function and, in particular, will remain in conformity with all the requirements on its safety, which apply.
The date itself shall be preceded by the hourglass symbol or the words: "Best used before the end of …".

For which purpose?
This is to prevent using a cosmetics, which may be no longer efficient, or which may pose risks to users. Some risks are not serious, such as a faded colour or fragrance, a less stable emulsion ; some are more critical, such as a less efficient preservative system …

Then, the consumer has to follow a rule: pay attention to this date and apply … if only to prevent any undesirable effect when using the product. If the date of minimum durability is over, the manufacturer is no longer liable for any trouble.

All the details and slight differences of understanding are to be found here. There is an add-on, in the Regulation: "Indication of the date of minimum durability shall not be mandatory for cosmetic products with a minimum durability of more than 30 months. For such products, there shall be an indication of the period after opening for which the product is safe and can be used without any harm to the consumer. This information shall be indicated, except where the concept of durability after opening is not relevant, by the " Open Jar " symbol followed by the period (in months and/or years)".

Particular precautions for use

In this part of the label, as a minimum, the requirements of the Regulation shall be displayed. As a first point, restricted substances, such as Boric Acid and its salts, which, if used, shall come with "Precautions to be observed" mentions, such as: "Do not use for children under 3" or "Do not used on scratched or damaged skin", just to give some examples. Indeed, more than 250 substances shall come with particular precautions.
Specific sentences are mandatory for some preservatives or UV filters.
The Regulation states that the manufacturer shall add the potential precautions specific for a professional use of cosmetics.

For which purpose?
The last report of Cosmetovigilance, issued by the French Afssaps , is clear: many of the undesirable effects linked to cosmetics are due to a wrong use, or because the precautions specified by the manufacturer have not been observed. Once again, the manufacturer cannot be held responsible if a consumer faces a problem when the product has not been used as recommended. Instructions and precautions shall be thoroughly followed.

True, they are not always easy to read on labels. Be they as small print on the label, or in a leaflet supplied along the product (the open-book symbol on the label let you know there is a leaflet), they shall be read…and followed.

The batch number of manufacture or the reference for identifying the cosmetic product

Where this is impossible for practical reasons because the cosmetic products are too small, for instance for make-ups, such information need appear only on the packaging. Nevertheless, it shall be mentioned somewhere.

For which purpose?
This mention, which gives the traceability of the product, is very useful, especially if an undesirable effect occurs liked to its use.
It makes it possible to point out the responsible parameter (an ingredient, an impurity in an ingredient, a faulty manufacturing process …), as to every batch number, a complete report is linked, in which everything, every parameter, from its design to its manufacture is recorded.
This makes it easy, if a batch is defective, to take back all the products of the same batch number, to prevent further undesirable effects in other users …

The function of the cosmetic product, unless it is clear from its presentation

Is "Moisturizing day care cream" easier to understand than "Morning Awakening" or "Dazzling Dawn"”? … You bet. Poetry (or ad people?) quite often put their mark on the names of our cosmetics, not helping in understanding what they are designed for …
Regulation does not forbid creativity, but requires clear and precise information.

For which purpose?
Just to prevent using a product in lieu of another one. There is no real risk if applying a night care cream in the morning, or using on one’s oily hair a shampoo for a sensitive scalp … Results may be not those hoped for … but no damage done.
However, this requirement helps to lower the occurrence of wrong uses, due to a mix up of products, with dramatic consequences. In 2009, the French Afssaps has recorded five occurrences of respiratory troubles due to cosmetic products mistakenly taken for single application physiological saline.

The list of ingredients

The list of ingredients shall be established in descending order of weight of the ingredients at the time they are added to the cosmetic product. Ingredients in concentrations of less than 1% may be listed in any order after those in concentrations of more than 1%.

The second point is that the list shall be exhaustive…but that some substances not considered as ingredients may lack; further, all the ingredients or a fragrance may be listed under the generic term e Fragrance " …

All the rules and exceptions about the list of ingredients may be found here .

For which purpose?
Already pointed out, again and again. In spite of its shortcomings and its uninviting INCI wording, the list of ingredients is the only reliable and mandatory source of information to guess the formula of a cosmetic product, hence its efficiency, safety and potential allergenic effect.
Better for all of us to understand it! Not that easy? This website is here exactly for that! To help you "translate" the INCI names, understand the function of the ingredients, and often more, when our experts have already evaluated them.
If the law-writers made it mandatory that users may access this kind of information, it is because they think you, consumers, have the right to know and that you are competent enough to make good use of it. Do you agree?


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